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Appendix
Annual Governance Statement
of the
Commissioner of Police of the Metropolis
Unaudited position as at 31 March 2015
including plans for the financial year 2015/16.
The Annual Governance Statement (AGS) is a statutory document which explains the
governance processes and procedures in place to enable the Metropolitan Police Service
(Met) to carry out its functions effectively. The Met is required to produce its own AGS
each year which must accompany the Met’s Statement of Accounts.
This document aims to provide you with an assurance that the Met is managing its
governance effectively and outlines how we will make further improvements to our
governance arrangements in the forthcoming year. This document takes into account the
opinion of our internal and our external auditors.
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Contents
Section
Page
A
Scope of responsibilities
3
B
Met strategy and challenges
4
C
The governance framework
6
D
Detailed review of Met governance
10
E
Governance issues and actions for 2015/16
28
F
Declaration
35
G
Glossary of terms
36
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A.
Scope of responsibilities
The Commissioner of Police of the Metropolis (CPM) is responsible for maintaining the
Queen’s peace and has direction and control over the officers and staff operating within
the Metropolitan Police Service (Met). The CPM holds office under the Crown and is
appointed by the Queen on the recommendation of the Home Secretary having regard to
any recommendations by the Mayor’s Office for Policing and Crime (MOPAC).
The CPM is accountable in law for the exercise of policing powers and to MOPAC for the
delivery of efficient and effective policing, management of resources and expenditure by
the Met. At all times the CPM, his constables and their staff remain operationally
independent in the service of the public. In discharging his overall responsibilities, the
CPM is responsible for establishing and maintaining appropriate risk management
processes, governance arrangements and ensuring that there is a sound system of
internal control which facilitates the effective exercise of these functions.
The CPM as an independent legal entity or corporation sole, with direction and control of
the force and responsibility for delivering operational policing, is legally required to produce
an Annual Governance Statement. The Statement helps MOPAC to hold the CPM to
account for efficient and effective policing. The Statement sits alongside the statutory
accounts for the Met and gives assurance to MOPAC of the Met governance
arrangements. MOPAC produces its own Governance Statement.
Under s.35 of the Police Reform and Social Responsibility Act 2011 in exercising his
functions, the CPM must ensure that good value for money is obtained and this includes
ensuring that persons under his direction and control obtain good value for money in
exercising their functions.
The CPM is required to appoint a professionally qualified Chief Financial Officer (CFO) for
the Met. Under the Police Reform and Social Responsibility Act 2011 the CFO has a
personal fiduciary duty by virtue of their appointment as the person responsible for the
proper financial administration of the Met. This includes requirements and formal powers
to safeguard lawfulness and propriety in expenditure (Section 114 of the Local
Government Act 1988 as amended by paragraph 188 of Schedule 16 to the Police Reform
and Social Responsibility Act 2011 (“2011 Act”)).
During the first part of the year the statutory responsibilities of the CFO were held by the
Director of Corporate Finance until a permanent Director of Commercial and Finance was
recruited mid September 2014. During that time the interim Director of Commercial and
Finance worked closely with the Director of Corporate Finance ensuring that the financial
affairs of the Met were properly administered in compliance with statutory requirements.
The Director of Corporate Finance was actively engaged with Management Board during
this time. Since mid September the statutory responsibilities of the CFO have been held
by the newly appointed Director of Commercial and Finance who is a member of the
Management Board.
Throughout the year the CFO role was involved in, and able to bring influence to bear on,
all material business decisions in line with the CIPFA Statement on the role of the CFO.
The CFO leads the promotion and delivery by the CPM of good financial management, so
that public money is safeguarded at all times and used appropriately, economically,
efficiently and effectively. This requires that the finance function is resourced to be fit for
purpose and appropriate management accounting systems, functions and internal controls
are in place so that finances are kept under review on a regular basis.
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B.
Met strategy and challenges
The MOPAC Police and Crime Plan 2013-16 sets three signal priorities for policing London
- cut crime by 20%, cut costs by 20% and improve confidence by 20% by April 2016. The
One Met Strategy define the Met’s response to these priorities, and the path to delivery:
The Met’s strategic objectives are:
Make London the safest global city
Earn and strengthen the trust and confidence of every community
Prevent crime and bring offenders to justice
Develop our policing capability whilst driving down costs
Embed a culture of professionalism in everything we do
In delivering these strategic objectives the Met faced significant challenges during 2014/15:

The successful implementation of the change programme and our ability to deliver
significant savings whilst improving service delivery for policing across London.

Successfully transforming our information and communication technologies (ICT) to a
capable, mobile-enabled set of systems that support policing.

Developing a strategic control framework to ensure that the Met effectively delivers on
strategic objectives in the MOPAC Police and Crime Plan 2013-17.

Embedding an ethical, values driven culture founded on integrity, courage, compassion
and professionalism to improve public confidence and policing outcomes.

Our imperative to improve engagement with all of our communities across London and
to develop our use of Social Media.
During the year an extensive programme of work took place to ensure that these
challenges were addressed which will continue into 2015/16.
Change programme
The Met has transformed how it operates over the past five years through ‘Met Change’
with large programmes managing change in technology, estates and our model for the
delivery of services. A service based approach to change has been adopted focusing on
five segments: Neighbourhood Policing, Pan London Services, Control Infrastructure,
Shared Support Services and Met HQ.
From April 2013 to March 2016 we will have reduced our costs by £600 million; releasing
old and underused buildings; changing our workforce mix by reducing police staff and
managers and reforming our operating model. All 32 Boroughs have moved to the new
Local Policing Model and we have protected the frontline including placing an extra 2,600
officers in Safer Neighbourhood Teams. We have released capital in order to build a
workplace and IT that is fit for modern policing.
The Met is now developing a new operating model, the One Met Model 2020 (OMM 2020),
for implementation by 2020. The OMM 2020 will set out our vision for policing in London
and how we intend to achieve that. It will describe the structures, systems, processes and
capabilities that we need to meet our strategic objectives. This will fully reflect the financial
reality in savings but also investment required. Development of this model to deliver a
predicted £800 million in savings by 2020 will continue throughout 2015/16.
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Financial challenges
The Met continues to face significant financial challenges. A number of key challenges
emerged in the 2014/15 financial year requiring additional savings of £105 million to
balance the budget. Whilst the outturn position is still being finalised, it is expected that
the Met will deliver a balanced position against the approved budget with a small
underspend.
The Met is planning to deliver total additional savings of £205m during 2015/16. The
savings will continue to be monitored closely in the forthcoming year.
Medium-term position:
There is currently no national guidance about the future funding challenges but this is
expected to become clearer in 2015. Therefore broad financial assumptions have been
developed to assist the planning process. It is estimated that between 2016/17 and
2019/20, the Met’s overall gross savings requirement could be £800m given the ongoing
austerity programme (and resulting reductions in government grants), likely inflation levels
for pay and non-pay costs, statutory changes that will affect the rate of national insurance
paid by the Met for all employees and provisions for in-year budget pressures.
Crime and confidence
Against this backdrop of change we have continued to focus on reducing crime. MOPAC 7
key neighbourhood crimes have reduced by 7% over the 2014/15 financial year, nearly
25,000 fewer offences. The Met remains on course to achieve the 20% reduction required
by MOPAC over four years to April 2016.
However the overall number of total notifiable offences (TNOs) increased by 0.9% (6,560
offences) over the comparison period. This is particularly due to increases in violent crime
and the reporting of sexual offences. These increases may largely have been driven
through improvements in crime recording, with significant emphasis on ethical recording
practices. The reporting of serious sexual offences, significantly of historic abuse, has
also been encouraged through high profile cases and heightened media coverage.
Recorded offences for some crime areas are increasing:
100
Violence without Injury
Offences (1,000s)
80
VWI
60
40
20
Sexual Offences:
2012/13: 9,859
2014/15: 14,711
2
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Rolling year to:
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Whilst other crimes are reducing:
100
Burglary
Offences (1,000s)
80
60
Theft from person
40
20
Robbery
2
3
4
2
3
4
2
3
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4
4
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Rolling year to:
We continue to develop initiatives and engage with communities to improve public
confidence in policing, and to meet the 20% improvement target in the MOPAC Police and
Crime Plan. When compared to our most similar forces nationally, confidence in policing
in the Met is above average at 62%, (as measured by the Crime Survey for England and
Wales). However, the target set by MOPAC of a 20% increase in confidence remains a
challenge which we are unlikely to meet by the end of 2015/16.
C.
The governance framework
During 2014/15 the Met updated its governance model in accordance with the IFAC/CIPFA
international framework for good governance in the public sector which was published in
July 2014. This builds on the previous model which was based on the CIPFA/SOLACE
Framework: Delivering Good Governance in Local Government (2007 and 2012).
This statement explains how the Commissioner of Police of the Metropolis has complied
with the code and meets the requirements of section 4 of the Accounts and Audit
Regulations (England) 2011 in relation to the publication of a statement on internal control.
In adopting this framework the Met fully accepts that:
Governance comprises the arrangements put in place to ensure that the intended
outcomes for stakeholders are defined and achieved.
Achieving good governance in the Met requires effective arrangements for:

Defining outcomes in terms of sustainable economic, social and environmental
benefits.

Determining the interventions necessary to optimise the achievement of the
intended outcomes.

Developing the Met’s capacity, including the capability of its leadership and the
individuals within it.

Managing risks and performance through robust internal control and strong public
financial management.

Implementing good practices in transparency, reporting, and audit, to deliver
effective accountability.
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The fundamental function of good governance in the public sector is to ensure that
entities achieve their intended outcomes while acting in the public interest at all
times.
Acting in the public interest requires:

Behaving with integrity, demonstrating strong commitment to ethical values, and
respecting the rule of the law.

Ensuring openness and comprehensive stakeholder engagement.
IFAC/CIPFA 2014
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Met governance model
The Met governance model focuses on a number of key frameworks, processes and other
internal controls to enable the Met to meet its strategic objectives and manage challenges.
These include:

Setting strategic objectives and
outcomes

Financial governance model


Change governance model
Strategic planning framework


Legal and regulatory compliance
Decision-making structures and
processes

Standards of behaviour and complaints

Risk framework

Capability and skills

Performance framework

Stakeholder engagement

Assurance framework
In developing this statement, eleven key areas of governance have been explored in
details as part of our annual review of effectiveness for 2014/15. These are:
Defining outcomes in terms of sustainable economic, social and environmental benefits
1
Processes for setting the objectives and targets that support the policing priorities
outlined in the Police and Crime Plan 2013-17, including reporting to MOPAC.
2
Decision making structures for establishing priorities and considering strategic issues
facing the Met.
Determining the interventions necessary to optimise the achievement of the intended
outcomes
3
Monitoring processes by which performance against operational, financial and other
strategic plans are considered and key issues identified and tasked.
Developing the Met’s capacity, including the capability of it’s leadership and the individuals
in it
4
Identifying the development needs of officers and staff in relation to their roles,
supported by appropriate training and linked to the priorities of the Met.
5
Incorporating good governance arrangements in respect of partnerships and other
group working.
Managing risks and performance through robust internal control and strong public financial
management
6
The risk management process by which the Met identifies and seeks to prevent and
mitigate key risks.
Reviewing and updating standing financial instructions, a scheme of delegation and
supporting procedure notes/manuals, which clearly define how decisions are taken
and the processes and controls required to manage risks.
Implementing good practices in transparency, reporting, and audit to deliver effective
accountability
Ensuring compliance with relevant laws and regulations, internal policies and
8
procedures and ensuring that expenditure is lawful.
7
9
Processes for receiving and investigating complaints from the public and providing
reports to Management Board and MOPAC.
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Ensuring openness and comprehensive stakeholder engagement
10
Establishing clear channels of communication with all sections of the community and
other stakeholders on priorities and plans.
Behaving with integrity, demonstrating strong commitment to ethical values, and respecting
the rule of the law
11
Developing, communicating and embedding codes of conduct and defining the
standards of behaviour for officers and staff.
Annual review of effectiveness
The Met is responsible for conducting, at least annually, a review of the effectiveness of
this governance framework including the system of internal control. This is undertaken
between March and May when governance areas are explored with senior leaders.
Management Board members have, for the 2014/15 fiscal year, been required to consider
and authorise a Statement of Internal Control for business areas under their direct
supervision. These statements clarify the extent to which members are satisfied that key
processes and internal controls in their area of responsibility are operating effectively. This
information informs this Annual Governance Statement, notably the governance
improvement plan 2015/16.
The review of the effectiveness of the Met governance framework is also informed by
regular reporting on operational and financial performance to Management Board and
through a corporate risk register which details key business risks and the controls in place
to manage these.
The review is further informed by internal and external review undertaken across the Met
including by Her Majesty’s Inspectorate of Constabularies (HMIC), our external auditor
Grant Thornton LLP, and our internal auditor the Directorate of Audit Risk & Assurance
(DARA).
Annual Governance Statement
This statement has been prepared for the 2014/15 financial year. It sets out the Met’s
current governance arrangements, reports on their effectiveness during the year and
outlines future actions planned to improve governance for 2015/16.
The detailed controls outlined below represent those at 31 March 2015 and up to the date
of approval of the Statement of Accounts and, subject to the areas identified for
improvement, accord with proper practice. These have been informed by the work of
senior officers and staff across the Met who have responsibility for the development and
maintenance of the governance environment, and in response to the opinion of the
Director of Audit Risk and Assurance.
The Director of Audit, Risk and Assurance’s (DARA) audit opinion for 2014/15 is that “The
Met’s internal control environment is not yet fully effective. The Met’s governance
framework has recently been revised to respond to the challenge of managing an
unprecedented level of change whilst maintaining effective policing services. Plans
developed to embed sound governance will help secure an effective internal control
framework supporting the achievement of policing priorities and objectives.”
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Controls for the eleven key areas outlined above for 2014/15 are reported in section D.
The seven improvement areas for 2015/16 are reported in section E.
D. Detailed review of Met governance
1. Processes for setting objectives and targets that support policing priorities outlined
in the MOPAC Police and Crime Plan 2013-17, including reporting to MOPAC.
Key controls to manage this activity
The MOPAC Police and Crime Plan sets the strategic direction for the Met (and other
criminal justice agencies in London) and outlines the Mayor’s requirements of the police
over a four year period. In response, the Met has developed the One Met Strategy. This
combines the MOPAC priorities with the Met’s national and international policing
responsibilities and defines a set of corporate objectives to deliver on those priorities.
Activity during 2014/15
In March 2014 the Met identified 15 key areas that drive delivery of the strategy, ranging
from understanding community needs, through quality leadership and employee
engagement, to operational delivery areas such as quality investigation and targeted
prevention. Throughout 2014/15 the organisation has been developing a corporate
scorecard based on these drivers, to give a rounded view of performance on the key
activity that will deliver the strategy and, in turn, the Police & Crime Plan. This approach is
now being cascaded to every unit across the organisation, so everyone understands how
their work contributes to delivering the One Met Strategy.
The Met introduced a new business planning process in early 2015, which is structured
around these 15 key areas and 2 additional challenge areas identified by Management
Board (confidence and responding to the increased threat from terrorism). Success
criteria, key enabling activity and challenges to delivery have been defined for each area
and used to build the 2015/16 Strategic Business Plan.
Within the One Met Strategy and the component objectives, the link to the Mayor’s
priorities and the MOPAC Police and Crime Plan is clear: the objectives align to the
20/20/20 vision and the requirements of the Plan are fully mapped across to the One Met
Strategy and/or the enabling strategies. Progress against policing priorities is reported to
the joint Oversight Board, where the Deputy Mayor for Policing and Crime and the
Commissioner oversee delivery of the Met strategy and budget.
Intended activity over the next year
As the Met looks forward to 2020 and the next comprehensive spending review, we will
refresh the One Met Strategy and design a new operating model for the Met - the One Met
Model 2020. Development work will follow a proven approach - understanding the future
operating environment for policing London, with a particular focus on understanding our
demand better and how our service impacts on our stakeholders, through a public
consultation.
The Strategic Business Plan provides an holistic view of planned activity across the Met to
assure Management Board and MOPAC that there are adequate plans in place to deliver
the One Met strategic objectives in 2015/16; support decision making and risk
identification; and enable the Board to hold leads to account for delivery. Leads will be
asked to report quarterly against their planned activity to Performance & Assurance Board
and look ahead at what will be required in 2016/17. In January 2016 leads will be asked to
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formalise these plans through the process to develop the next Strategic Business Plan,
taking into account the activity planned to deliver the One Met Model 2020.
2.
Decision making structures for establishing priorities and considering
strategic issues facing the Met.
Key controls to manage this activity:
A number of significant changes to joint Met/MOPAC governance processes and to
internal Met decision making and reporting processes have taken place in 2014/15. These
were designed to clarify Met decision making and MOPAC scrutiny. Management Board
agreed proposals in late 2013 which were implemented by the start of the 2014/15 year.
Joint Boards:
Oversight Board: Chaired bi-monthly by the Deputy Mayor for Policing and Crime and
attended by the Commissioner this Board exercises MOPAC’s responsibility for oversight
of the Met. This Board initiates, approves and oversees delivery of the budget and key
strategies to deliver the Police and Crime Plan and the Met Strategy.
Joint Investment Board/Joint Asset Management Panel: Chaired by the Deputy Mayor for
Policing and Crime these meetings ensure that Met investment decisions relating to goods,
services, property acquisitions and disposals are founded on sound business cases, meet
budget targets, provide value for money and support strategic direction.
Joint Met/MOPAC Audit Panel: The quarterly independent panel advises both MOPAC
and the Commissioner in accordance with good governance principles. This includes the
provision of assurance on behalf of MOPAC and the Commissioner on the adequacy and
effectiveness of the frameworks in place to discharge legal duties in relation to health and
safety and equalities and diversity.
The Panel receives regular reports from the Met on significant risks, findings from audits
and inspections and analytical data relating to the acceptance of gifts and hospitality. The
Audit Panel provides independent advice to the Commissioner and Deputy Mayor as to the
integrity of the financial statements.
Met Boards:
The Met Management Board, chaired by the Commissioner, is responsible for ensuring the
Met has a corporate governance framework that reflects the principles of openness,
integrity, accountability and equality, and supports the delivery of quality policing. During
2014, Management Board met in a variety of forms to ensure appropriate focus was given
to areas that are essential in delivering effective governance:
Management Board Strategic: Agreed the One Met strategy and enabling strategies and
ensured ownership in the Met. It approved the draft budget and considered the Met’s
future direction by assessing strategic challenges and engaging in the national debate.
Management Board Assurance: Ensured that the Met had fully effective internal controls
which enable delivery of Met objectives. Specific responsibilities include ensuring the
accountabilities of officers and staff are defined and complied with, overseeing significant
risks and ensuring that an effective risk management and audit and inspection framework
is in place, reviewing key decisions to ensure compliance with Met governance processes.
Management Board Performance: Was responsible for addressing strategic performance
challenges and overseeing operational delivery in line with Met strategy and objectives.
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Management Board Investment: Oversaw and prioritised investment decisions including
the capital plan to ensure delivery against Met strategy and objectives.
Management Board Change: Oversaw the delivery of all change in line with Met strategy.
Management Board People: Was responsible for delivering the People Strategy including
workforce planning and professional standards.
Activity during 2014/15
These corporate decision making structures and processes have been amended during
2014/15 to ensure that the relationship between Boards and accountability for decision
making is clear. Changes were agreed by Management Board in September 2014 and the
Met has transitioned to a new model between January and March 2015. This has reduced
Executive Boards from six to three: Management Board, Investment & Resources and
Performance & Assurance Boards. These are supported by a new Portfolio Delivery
Design Board which reflects the significant portfolio of change the Met will deliver over the
next four years. Its remit is to ensure that all proposed change is in line with the overall
One Met Model 2020 and to manage delivery of change programmes.
Intended activity over the next year
We will embed and refine amended structures and processes during 2015/16 to ensure
that our decision making structures are fit for purpose and result in robust decision making
around investment and improved rigour around the oversight of delivery of corporate
strategies.
3. The monitoring processes by which performance against operational, financial and
other strategic plans are considered and key issues identified and tasked.
Key controls to manage this activity
Performance control:
The Met has a well established performance framework which connects performance
discussions at Management Board level through business groups to individual command
units. The performance framework is now being developed to introduce a 'balanced
scorecard' approach to give line of sight from individuals' objectives to the Met's strategy.
From March to May 2014 the key drivers of the strategy were determined in a series of
workshops with senior colleagues. These drivers now form the framework for Management
Board's performance meetings and for the 2015/16 Met business plan. The same drivers
are now being used to develop scorecards for every business unit in the Met - both
operational and non-operational - with the intention that everyone will have this new type
of scorecard in place by July 2015.
In the past year the Met's performance service has been centralised to provide a single
source of analysis and data to support performance conversations in the Met.
Assurance control:
Work has been ongoing throughout 2014/15 to strengthen audit, inspection and review
services in the Met. The Met operates the “three lines of defence framework” which
provides assurance at three levels. These are: first line - business operations risk control
and performance management, second line - organisation oversight functions and third
line - independent and internal audit assurance.
Regular reports were submitted to Management Board - Assurance (now Performance and
Assurance Board) and the Joint Met/MOPAC Audit Panel throughout 2014/15. These
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provide assurance that audit and inspection recommendations are being addressed and
that the framework is continuously improving. In the coming year further work will take
place to understand where audit and inspection is focused throughout the Met and to
identify any gaps in this so that resources can be targeted at the areas of greatest risk.
The system of internal control is a significant part of this framework and is designed to
manage risk to a reasonable and foreseeable level. It cannot eliminate all risk of failure to
achieve policies, aims and objectives. It does however provide reasonable, though not
absolute, assurance of effectiveness.
Financial control:
Key controls to manage this activity
The Met’s financial governance framework comprises longer term financial strategy,
developing robust and deliverable budgets, providing professional financial advice within
the year to support decision making, regular financial management information and prompt
final accounts. This is supported by financial governance structures, financial systems,
policies, people and controls across the Met to safeguard, deliver value for money and
achieve a balanced year end budget. The Met is in the process of developing a culture of
devolved local accountability whilst promoting effective internal control.
Activity during 2014/15
MOPAC and Met governance arrangements have matured, with Management Board
approving the annual budget before submission to the Deputy Mayor for Policing and
Crime. Investment & Resources Board make recommendations to the Joint Investment
Board on spending options with a value of over £0.5M, approve outline and final business
cases in line with the Scheme of Financial Delegation, ensure that financial decisions are
informed and that risks, impacts and costs/benefits are considered.
Management Board members are responsible for agreeing their budgets and maintaining
expenditure within this to ensure effective financial control. Members and budget holders
are responsible for accurate recording of income and expenditure against respective
budgets - Finance Business Partners (FBPs) provide support with Corporate Finance.
In ensuring tight budgetary control, Board members and budget holders rely on local
forecasting and variance analysis within monthly monitoring reporting (MMR). This is
overseen locally by FBPs ensuring that local explanations for all significant variations
against budget are reasonable. Corporate Finance oversees the whole budgetary
planning process and provides the monthly MMR to Management Board and MOPAC.
Effective stewardship at a local level essentially means ensuring that managers and staff
under each Member’s command are compliant with the relevant regulations, policies and
procedural guidance, achieve value for money and ensure effective checks and balances
exist.
During 2014/15 we:
 Began developing our financial modelling capacity with a view to delivering a
comprehensive Financial Strategy in 2015/16, providing clear financial planning
assumptions for the organisation.
 Published a balanced budget for 2015/16.
 Developed and published our first Investment Strategy introducing the Treasury Green
Book methodology to strengthen key decision making.
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 Improved the quality of our financial advice to key decision makers.
 Tackled and improved financial management within Digital Policing.
 Undertook financial housekeeping more evenly across the whole year as part of faster
closedown. This improved monthly and year end monitoring and our ability to identify
potential irregularities.
 Drove faster goods receipting by the business to reduce the number of manual accruals
in the accounts.
 Introduced in year balance sheet reporting to improve the quality of financial reporting,
including client performance indicators to reassure the Chief Financial Officer on the
maintenance of an effective finance function.
 Closed the accounts at Period 10 to enable statutory accounting and external audit work
to undertaken prior to year end, to enable year end accounts and external audit process
to be completed earlier by July in line with central government departments. This will
improve the efficiency and quality of management information for policy and planning
and also enhance governance by identifying financial issues and irregularities in time to
deal with them quickly.
Intended activity over the next year:
The Met’s financial strategy will address our savings requirement (outlined in section B) by:
maximising future frontline spend by limiting back office expenditure to about 15% by
2019/20; improving productivity by some 20% in our frontline service and seeking to
transform our services with other partners and the public. This will incorporate a range of
supporting strategies such as: capital, value for money, insurance and reserves. Key
planned improvements are:
 Financial accountability and responsibility will be improved by ensuring more rigorous
corporate analysis and will be regulated by an updated Scheme of Devolved Financial
Management which operates as a key financial internal control and is a main element of
the MPS Financial Governance Framework. The principal behind devolving budgets is to
ensure those officers and staff with responsibility for committing expenditure are
accountable. This is a fundamental shift in strategy from recent years where we have
increased central control to ensure delivery of savings. The financial challenges facing
the MPS are well known and whilst centralisation has reaped benefits with regards to
the initial tranche of savings, there is now an increasing reliance on local control of
budgets to ensure we deliver to existing commitments and to support and own the
implementation of the One Met Model 2020 as we move forwards.
 The Investment Strategy will be updated to fit more closely the updated governance
framework and delegations.
 The monitoring and reporting process will be improved to provide more transparency to
both corporate and business performance and management action.
 We will close our accounts even earlier next year.
It should be noted that during 2015/16 the finance function will reorganise and reduce in
size. This will be in line with the Business Support Services commercial strategy where the
transactional workload within HR, Finance and Procurement will be outsourced within the
coming months. This will enable the finance function to focus entirely on the key priorities
of the MPS.
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4. Identifying the development needs of officers and staff in relation to their roles
supported by appropriate training and linked to the priorities of the Met.
Key controls to manage this activity
The Met recognises the need to define effective training and development, ensuring that it
is fit for purpose and actively supports our objectives. The Met People Strategy 2013-17
has identified one of the signal people challenges as thinking radically about how we equip
our staff with the capabilities, skills and knowledge to do their job.
Activity during 2014/15
The Met’s new training governance process was put into effect in 2014/15. The Strategic
Training Meeting (STM), chaired by Director HR and attended by chief officers and staff
identified emerging priorities and capability requirements in order to set strategic direction
and priority training areas for the training delivery plan. This is supported by a Tactical
Tasking Meeting (TTM) which has responsibility for delivering the priorities set by the STM
and acting as the gateway for all training commissioned in the Met. The development
needs of our officers and staff are continually assessed against national standards set by
the College of Policing in all areas of volume and specialist training provision.
Extensive work is underway to focusing on the quality of training interventions by reviewing
our syllabus and course content to ensure that we are improving capability and
performance to deliver policing outcomes. One example is making sure that we are
drawing on evidence based practice and what works in policing.
The development needs of officers and staff are continually assessed against national
standards laid down by the College of Policing in all areas of volume and specialist training.
Further governance measures will assess externally purchased training across the Met
through capability requirements and return on investment, prioritised against skill
requirements. This process coupled with the introduction of a managed service provider to
procure such training will continue to deliver improved efficiencies.
Intended activity over the next year:
We will continue to drive efficiency within training delivery by exploring different delivery
models. This year with further investment in mobile technology the Met will look to develop
innovative learning interventions available to officers outside of the classroom environment.
In 2015/16 we will invest in improving investigation skills to uniformed borough
investigators, improving cyber capability and a refreshed recruit foundation course. We
will continue to develop learning interventions available to our staff through e- learning,
professional development days and access to academic study and continual professional
development. We will develop leadership ability at all levels. ‘Leading for London’ is a
nine month leadership development programme with a focus on leading change,
embedding skills to create a culture of continuous self-sustained and business
improvement. After pilot study evaluation our ambition is to deliver across all commands.
We will initiate "business" training both across the organisation and in HQ to support the
move towards multi year financial strategy, devolved budgets and restructuring of the
finance function, and the outsourcing of significant transactional activity and how that is
controlled. This also applies to our expectation around more "commercial" thinking - at its
most basic an understanding of costs and performance.
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5.
Incorporating good governance arrangements in respect of partnerships and
other group working.
Key controls to manage this activity
A corporate partnership policy and toolkit is in place. Financial partnership arrangements
are recorded on a central database, monitored by the Finance team and reported to
Management Board as part of the budget monitoring process.
Activity during 2014/15
Governance of Met partnerships has been enhanced with the introduction of a corporate
partnership policy and toolkit, which puts in place controls for all partnerships that meet
agreed criteria in relation to longevity, value, resourcing and risk associated with the
partnership. The toolkit launched fully in July 2014. It includes checklists, guidance and
templates.
The partnership policy and toolkit is accessible via the Met intranet and provides
instructions, advice and guidance for all officers and staff relating to entering, managing
and finally closing partnership arrangements. It is mandatory to use the policy for all new
corporate partnerships that meet the agreed criteria. It will ensure that all new Met
partnerships are supported by a business case, clearly defining benefits, risks, investment,
consultation and business impact of the partnership.
A best practice network of partnership leads is in place with 25 leads across the Met. The
partnership leads provide guidance and support to colleagues considering a partnership,
and the use of the partnership toolkit.
Intended activity over the next year:
During 2015/16 the strategic intent is to focus on our significant partnerships across all
areas of service delivery through the One Met Model 2020. This includes existing
initiatives such as the National Procurement Hub, enhanced ‘blue light’ collaborations and
scenarios such as new public collaborations and a revised neighbourhood model. We
intend to deliver a plan for blue light collaboration with London Ambulance Service and
others within 12 months A comprehensive partnership mapping exercise is underway to
inform activity and “developing effective partnerships” is a key element of the One Met
Scorecard which is currently being rolled out across the Met. The application of the
partnership toolkit across the Met will be reviewed through dip sampling during 2015/16.
6. The risk management process by which the Met identifies and seeks to prevent and
mitigate key risks.
Key controls to manage this activity
The Met risk management framework is in place to support effective decision making and
provide assurance that risk is managed effectively at all levels. The framework operates at
three levels; corporate, business group and basic command unit.
In a 2014 audit, the risk framework was judged by DARA to be at level 2 maturity with
clear evidence that it is moving towards level 3 (against a maturity model where 1 is the
lowest score and 5 the highest). Level 2 represents a position where Management Board
are taking the lead to embed risk management, roles and responsibilities are defined and
resources are in place to further implement risk management processes which are not yet
fully embedded. Until the Met risk management framework is more fully embedded it is
unrealistic to expect that the internal control environment will be fully effective, in line with
our internal auditor DARA’s opinion.
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Activity during 2014/15
A number of risks registers are in place and regularly reviewed to ensure that appropriate
controls are in place for the management of significant risks. These are:
Strategic corporate risk register: This has matured significantly in 2014/15. It is reviewed
quarterly by Performance and Assurance Board, chaired by the Commissioner. Risks are
regularly escalated to this meeting for consideration. Improvements to reporting processes
have enabled better quality risk discussions to take place, improving decision making in
the management of the risks. Corporate risks are subject to a more in-depth review by
Management Board throughout the year.
Operational risk register: Corporate operational risks are managed through the Risk and
Organisational Learning Meeting, chaired at AC level this was introduced in July 2014.
Significant operational risks are reviewed on a 6 weekly basis by the members to ensure
the risks are effectively managed. Risks are regularly escalated to this meeting for
consideration and from this meeting to Management Board when appropriate.
Portfolio risk register: Reviewed quarterly by Change Portfolio Board in 2014, this register
captures significant change portfolio risks. Risk management within change programmes
and projects is well established and monitored through programme and project boards.
Business group level risk registers: These registers are discussed at least quarterly by
chief officer groups at the business group level and capture risks which have been
escalated from basic command units either because:

They could require decision making regarding a change of priority or resource
allocation at a more senior level or;

They could have significant impacts if they occur and a corporate level Board should
accept the level of risk being carried by the Met.
Intended activity over the next year:
Management Board have a target to achieve level 3 risk maturity by September 2015. An
implementation plan is in place to achieve this which includes:
 Refreshing the corporate risk register;
 Developing a risk appetite statement;
 Conducting a risk control mapping exercise;
 Conducting risk maturity assessments in each business group.
Business Continuity:
The Met has plans in place to ensure business continuity following disruptive incidents.
Regular risk assessment of pre-planned works and collaboration between stakeholders
takes place to ensure that disruption is not caused, or that the impact of disruption is
minimised, in the operational environment. Real time implementation of plans to protect
critical activity has been successfully executed in several cases, including and during
groundwater flooding in February 2014.
The level of testing of Operational Command Unit (OCU) and Business Unit Business
Continuity Plans is persistently below our target delivery. To address this issue we have
deployed additional resources, have identified external professional tuition and academic
qualifications for key staff, and ensured a continued emphasis on addressing performance
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indicators in training and through personal contact with business area and OCU
representatives throughout the year.
Insurance:
Key controls to manage this activity
The Met continues to maintain, develop and renew its insurance programme in order to
ensure appropriate cover of risks. An annual report is completed for MOPAC on renewal
outcome and strategy. The Met employs a qualified in-house insurance professional to
manage insurance, who in liaison with the appointed insurance broker ensures that all
insurance policies are suitable. The insurance manager works with the Met procurement
team to ensure that all contracts are procured in line with legislation.
Intended activity over the next year:
A review of insurance strategy has been commissioned by the Director of Commercial and
Finance and a new strategy will be documented, communicated and implemented over the
next year.
Health and Safety:
The Met Safety Management System (SMS) is enshrined in the MOPAC and Met
Corporate Health and Safety Policy. Annually all Occupational Command Unit, department
and Business Group leads provide assurance regarding their SMS to the Commissioner,
identifying areas for improvement. An annual health and safety letter of assurance is
provided by the Commissioner to the Deputy Mayor. The Safety and Health Risk
Management Team audit operational thematic and safety management performance. The
Property Services Compliance Team audits property and fire safety. Met safety
governance is coordinated via the Met Health and Safety Board; this is reported to
Performance and Assurance Board and the Met/MOPAC Joint Audit Panel.
7. Reviewing and updating standing financial instructions and supporting procedural
documentation, which clearly define how decisions are taken and the processes
and controls required to manage risks.
Financial Instructions are reviewed and updated regularly to ensure they remain fit for
purpose. Financial Instructions are a key element in the financial governance framework
and are part of a hierarchy of documents which define accountabilities, identify how
decisions are taken and ensure legal and procedural compliance.
These include the:

Financial Regulations

Good Conduct and Anti-Fraud Policy

Contract Regulations

Detailed Financial Instructions

Schemes of Consent and Delegation between MOPAC and the Met
MOPAC is responsible for reviewing and updating MOPAC Group Financial Regulations,
the Good Conduct and Anti-Fraud Policy and Scheme of Consent and Delegation between
MOPAC and the Met. The Commissioner, Management Board Members and the Director
of Commercial and Finance are consulted on any changes and updates.
The Director of Commercial and Finance is responsible for maintaining the Financial
Instructions. The Financial Instructions represent the application and interpretation of the
Financial Regulations applicable to the Met. The Financial Instructions and other key
financial standard operating procedures and toolkits are stored on the corporate policy
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database on the Met intranet and are reviewed on a regular basis. For instance the
Financial Instructions are reviewed every two years and updated accordingly.
Each Financial Instruction has a designated owner (sponsor) responsible for performing
the review. All proposed changes by the Corporate Finance Director are ultimately signed
off by the Commercial and Finance Director before seeking endorsement from the CFO of
MOPAC prior to publication. Within the Met, it is the responsibility of each Chief Officer
and unit head to ensure that all relevant staff within their service area are familiar with the
Financial Instructions.
Over the last three years there has been a series of changes to the Scheme of Delegation
to reflect new arrangements under the Police Reform and Social Responsibility Act 2011.
From 1 April 2014 the Scheme of Delegation was renamed as the Scheme of Consent and
Delegation following the transfer of police staff to the CPM under Stage 2 of the transition.
The changes were cascaded and relevant procedural guidance amended (below).
Policies and procedural guidance are updated regularly. One of the responsibilities of
senior finance staff, who are involved in key projects and change programmes, is to
identify where changes will need to be made to the procedural guidance and policies.
Managers responsible for those areas will then update the guidance. For instance the
Scheme of Devolved Financial Management has been revised in response to the One Met
Model change programme and second stage of the Police Reforms.
Accounting policies are reviewed on an annual basis. Any significant accounting policy
changes must be approved by the MOPAC and Met CFOs. The Audit Panel will also be
notified of any significant changes for consideration.
The Regulations, Instructions and guidance are key to ensuring the financial affairs of the
Met are properly administered having regard to probity, legality and appropriate standards.
As part of this framework the Directorate of Audit, Risk and Assurance (DARA) and the
external auditors have a keen interest in ensuring that the financial policies and guidance
are up to date and relevant and this is an area that is closely monitored within many of
their reviews.
8. Ensuring compliance with relevant law and regulations, internal policies and
procedures, and that expenditure is lawful.
Law and regulations:
Processes for ensuring compliance with relevant law and regulations are well established.
Reports to the Met Management Boards together with reports presented to MOPAC must
consider legal and financial implications, and the Director of Legal Services attends
relevant Boards as an adviser. The MOPAC Scheme of Consent and Delegation gives
authority to the Directorate of Legal Services (DLS) to approve the settlement of claims all significant claims require MOPAC approval. The MetLaw reception desk monitors
requests for external legal advice, and emergency out of hours legal advice is available.
All Met Legal Services are routed through DLS thereby providing better control and join up
of services and budgetary control of this area.
There are, despite robust processes, implementation and compliance issues including
Diversity and Fairness at Work failures highlighted by high profile tribunal cases and some
issues regarding compliance with the Working Time Directive. The Met has established
Gold Groups chaired at a senior level to investigate and develop solutions to these issues.
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Policy:
Activity during 2014/15
The Met Policy Framework underwent significant change from 2012 to March 2014, and
the revised framework is working well. Policy is accessible via the intranet from Met Policy
Pages. All neighbourhood policing policy and standard operating procedures have been
converted into policy toolkits which are quick and easy to use.
The Commissioner’s Strategy Forum meets bi-monthly and reviews and approves high risk
policies in accordance with the corporate policy review plan. Medium/low risk policies are
approved by Chief Officer Groups at the business group level. All policies are subject to
equality impact assessment carried out with advice and guidance from the Corporate
Policy Unit to ensure that the Met meets its public sector duty under the Equality Act 2010.
Work is ongoing to provide a more streamlined and efficient policy development process.
Bespoke action plans for policy developers will provide clear guidance on consultation,
equality impact assessment and clear timelines for corporate quality assurance and
approval. Policy owners remain responsible for ensuring their respective policies are
monitored regularly and remain fit for purpose.
Intended activity over the next year
The intention over the forthcoming year is to drive the policy review plan to ensure that all
high risk policies are brought up to date and are equality compliant by March 2016. In
addition, to tracking progress of the One Met Model programme, so that 'gaps' in policy
can be identified and commissioned. A review of medium/low risk policies will be carried
out to ensure only those policies that support delivery of the One Met Model are retained.
Procurement:
Procedures are in place to give rigour to procurement decisions at Management Board Investment and Resources, Procurement Board and to Joint Investment Board.
Purchasing processes are regularly reviewed to ensure compliance with Met policies and
procedures and a Procurement Review Panel has been introduced to ensure that the right
procurement strategy is in place at the outset of the process. Results from quality
assurance reviews show that the process for the letting of contracts has progressively
improved since 2011. The quality assurance process will be refreshed this year to build
further checks into each stage of the process. The EU reforms to the Public Contract
Regulations 2015 are being adopted through training, e-learning and specific workshops.
Information Management:
Activity during 2014/15
A new Information Security and Assurance Board (IASB) was formed in December 2014
replacing the previous METSEC Board. IASB chaired by Assistant Commissioner Professionalism is responsible for information management (including Data Protection and
Freedom of Information compliance). The Board is supported by sub-groups leading on
Personnel Security, Physical Security, Information Assurance & Technical Security and the
Strategic Crime & Incident Reporting Group. During 2014/15 AC Professionalism held the
role of Senior Information Risk Owner.
IASB receives regular progress reports on mitigating actions for information management
and information security risks. During the year an information management risk 'deep
dive' was undertaken by Management Board - Assurance.
Other improvements in information management include:
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 The Records Management toolkit was reviewed and amended during 2014 and the
supporting implementation plan approved at Commissioner's Policy Forum. The revised
working practices will be rolled out across the organisation over the next two years. This
work directly supports the Met response to the Ellison Report under the operation title
Filesafe.
 The METSEC Code has been reviewed as part of a regular cycle with the updated
version issued in April 2015.
 The mandatory computer based training package 'Computers and You' which provides
baseline training for all officers and staff in information law, protective marking and
security has been reviewed and reissued.
 The Local Security Champion network remains active - a support event was held in
December 2014 to provide updates and supporting information to Local Security
Champions.
 As part of the Met recovery action plan to improve the organisations performance
against the statutory time limits for Freedom of Information Act requests all business
group leads have been provided with weekly performance information on information
requests within their business areas. This has resulted in significant improvements in
performance.
 An Information Management Strategy is being prepared to set out the Met’s objectives
for information management. This will be finalised by June 2015.
 A recovery action plan has been in place since April 2014 to improve corporate
performance with Data Protection Subject Access and Freedom of Information requests.
This has involved additional temporary staff supporting our subject access response
staff and intensive management action to drive up performance on Freedom of
Information requests dealt with by business groups. This has resulted in improvement
over the year.
 In addition a review has taken place of our existing delivery model and a business case
made to centralise our processes for dealing with Freedom of Information requests and
increase resources centrally for dealing with Data Protection subject access requests.
Proposals were agreed and work is underway to implement this sustainable model.
Intended activity over the next year:
In support of the Records Management Implementation Plan we will conduct information
management maturity assessments at sites 3 to 6 months after implementation of the
records management toolkit to measure the level of maturity in local practices. This will
provide a complete picture of the organisations maturity and identify further areas of
improvement for Information Security and Assurance Board.
We will also: review the Met Records Retention Schedule in light of a recent Supreme
Court judgement to ensure that this is compliant with relevant legislation; implement the
Government Security Classification Scheme within the Met once national police guidance
and training material is finalised: and conduct information assurance audits in line with the
agreed audit plans of Information Security and Assurance Board.
Diversity:
Key controls to manage this activity
The Met continues to work to recognise the requirements of the Equality Act 2010. The
Business Change and Diversity resource is situated within Met Headquarters and has
strategic responsibility for building and steering corporate activity. Throughout 2014/15
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quarterly reports on the diversity framework were submitted to the Joint Met/MOPAC Audit
Panel.
Activity during 2014/15
A Strategic Inclusion, Diversity and Equality (STRIDE) strategy has been developed during
2014/15 with the aim of providing an overview and framework for corporate activities. This
approach builds on the diversity and equalities work the organisation has been involved in
to date. The strategy will focus on three strategic areas: service delivery underpinned by
community engagement; inclusion; diversity and equality including the implications for
cultural and behavioural change and organisational policies and processes.
The Met People Strategy continues to engage and invest in its ambition to build a Met
which reflects the diverse make up of London, especially in race and gender. On the
operational front, policy changes to stop and search, greater emphasis on service delivery
improvements to victims of hate crime and our service with regards to mental health issues
continue to be of note. Considerable work has taken place to improve community
engagement activities at borough level and in our work on counter terrorism.
Intended activity over the next year
The STRIDE strategy will continue to develop and be overseen by a board that will be
responsible for championing and monitoring corporate delivery with local senior
management teams responsible for local delivery. Moving forward the intention is to raise
the organisation's level of awareness on matters of disability and also those of a
multigenerational workforce.
We will also act on the Equality and Human Rights Commission (EHRC) investigation of
the Met into the handling of staff complaints and grievances, and a parallel review which
we have commissioned from the Acas) to advise on new policy and governance
arrangements for handling staff grievances. The report will be delivered this year.
Environmental:
The Met is committed to environmental sustainability which addresses the responsible
management of the environmental impacts of the Met. This is implemented through an
environmental management system (EMS) focusing on policy implementation, legislative
review and performance monitoring, including implementing Mayoral strategies and targets.
The Met’s Sustainability Management Programme, monitored by the Environment and
Sustainability Board, aims to meet our environmental commitments and deliver continuous
improvement. Performance is reported through the annual Met Environment Report.
During 2014/15 a formal review of the EMS was undertaken and work is ongoing to
improve alignment to ISO 14001, the best practice standard for environmental
management. The latest version of ISO 14001, due to be published during 2015 and
contains new requirements assigning specific responsibilities for those in leadership roles
to promote environmental management within the organisation. Property Services
Department is responsible for managing the implementation of the EMS on behalf of the
organisation.
9. Processes for receiving and investigating complaints from the public and providing
reports to Management Board and MOPAC.
Key controls to manage this activity
Complaints: Processes for dealing with complaints against the police are governed by
Acts of Parliament, Home Office guidance and Independent Police Complaints
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Commission (IPCC) statutory guidance. The Police Reform and Social Responsibility Act
2011 introduced new regulations, building on the Police (Complaints and Misconduct)
Regulations 2012; the Police (Performance and Conduct) (Amendment) Regulations 2012;
the Police Appeals Tribunal (Amendment) Rules 2012; and the Police (Conduct)
Regulations 2012. In turn, new Home Office guidance and new IPCC statutory guidance
were published. Met policies and procedures have been reviewed and amended to
accommodate the changes.
Overarching Met policy is set by the Professional Standards Strategic Committee (PSSC)
and captured in the Professional Standards policy. This is supported by standard operating
procedures (SOPs) and equality impact assessments (EIAs). The main internal guidance
for dealing with complaints is the Misconduct Investigation guide, and this is supported by
the Guide to the Local Management of Misconduct Proceedings, which is aimed at
Operational Command Units (OCUs).
Complaints are co-ordinated by the DPS Complaint Support Team (CST) which assesses,
records and allocates the complaint for action, and initiates service recovery where
appropriate. Complaints made by phone are directed for local resolution and, if
unsuccessful, forwarded to the CST. The recording of a complaint is a process governed
by legislation. The Met record of complaints is the Tribune IT system. Legislation also
details appeal rights for the complainant and, depending on the seriousness of the
complaint, the Force or the IPCC deals with these.
The CST assesses whether a referral is a complaint or other matter, and then whether the
complaint is suitable for local resolution without formal investigation. Only complaints
defined by legislation as less serious can be locally resolved. Allegations amounting to
misconduct or gross misconduct (misconduct is defined as a breach of the Professional
Standards for Police Officers, gross misconduct as a breach so serious that dismissal
would be justified) are referred to either the DPS Serious Misconduct Investigation Unit
(SMIU) or, with misconduct allegations, to OCU Professional Standards Champions
(PSCs), supported by Professional Standards Units.
If a complaint is suitable for local resolution it is referred in line with IPCC statutory
guidance and the misconduct investigation guide. The complainant is informed in writing
of the action taken and has a right of appeal against the outcome. If a complaint is
assessed as not suitable for local resolution an investigation must follow in line with IPCC
Guidance and the misconduct investigation guide or local misconduct investigation guide.
The Investigating Officer determines whether the complaint is upheld or not and whether
this is due to misconduct. Appropriate action is taken and the complainant is informed.
The complainant has a right of appeal against the investigation and the outcome.
When the failing is at an organisational level the matter is taken forward by an NPCC
(formerly ACPO) level lead and progress is monitored by DPS Prevention and Reduction
Team. Where misconduct is identified for an OCU case, the matter is referred to the OCU
PSC for review. For a DPS gross misconduct case, it is referred to the DPS Hearings Unit.
The complainant is kept updated with the progress of misconduct proceedings and has a
right of appeal over the investigation, the conclusions and the proposed outcome. At the
conclusion of proceedings the full report is provided to the complainant.
Other Citizen Redress: The main form of citizen redress other than the complaints
system is through civil action. Claimants are referred to the Directorate of Legal Services
(DLS) where a DLS lawyer is supported by the DPS Civil Actions Investigation Unit (CAIU)
and the DPS Public Order and Civil Enquiry Team (POCET). POCET gathers all the
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available evidence from large scale public order situations whilst the CAIU performs the
same function for other civil claims. Each civil claim is initially reviewed to determine
whether any allegations should be recorded as conduct matters and investigated - any
criminal or conduct investigation would normally take precedence over the civil action.
Reports: Reports are provided in full (subject to the harm test) to all complainants and to
any advocate assisting the complainant. The report is provided without further direction.
Reports can also be provided to any interested party through a Freedom of Information Act
(FoIA) application, with redactions where necessary. The Performance Analysis Unit
(PAU) provides reports, data and analysis on public complaint and misconduct issues
including regular updates to the Independent Police Complaints Commission (IPCC).
Controls: Professional standards policy is managed by the Professional Standards
Strategic Committee, chaired by the AC - Professionalism. Each Met directorate has an
ACPO lead for professional standards. The DPS Deputy Assistant Commissioner (DAC)
chairs a quarterly Professional Standards Performance Board, currently addressing
complaint reduction and trends, and also a monthly Senior Investigating Officer’s meeting
in which progress in high risk DPS investigations is reviewed. The DPS OCU Commander
chairs a weekly Command Team Meeting that reviews progress on all high risk
investigations and issues across the Command, monitored via the DPS risk register.
Activity during 2014/15
The Met is continuing to drive improvements in processes, skills and performance in
response to the major changes to legislation and regulations introduced in 2012. A
significant new Professional Standards and Misconduct training course has been
introduced. DPS are working on projects with the IPCC to improve collaborative working,
agree common standards and reduce the number of appeals made (and upheld) as well
as the number of re-investigations. This has delivered a drop in appeals and work is
ongoing. DPS hosts bi-annual seminars for OCU PSCs to debate strategic and emerging
issues and good practice with the IPCC.
DPS is developing pro-active preventative processes that identify organisational risks and
trends and direct interventions where appropriate. Currently the four OCUs that require
most support with professional standards issues are identified through Borough Support
Management Information (BSMI) data and are given specific support. BSMI data is also
used to support the Complaints Intervention Scheme. This identifies any officer with three
or more complaints in the previous twelve months and provides for an individual action
plan. This data is further developed to identify officers who present a greater risk to the
organisation, assessed against a risk matrix. Any officer who passes a certain threshold is
subject to a comprehensive action plan developed by DPS with line managers.
DPS are currently developing practices for the delivery of public hearings for police gross
misconduct discipline cases, which was introduced in legislation by Government in March
2015. This will mean all hearings will be in public unless the chair determines otherwise.
The impact of this is being worked through at present. The other legislative change being
monitored is that no officer is able to resign/retire if they are under investigation for a gross
misconduct matter or a misconduct matter where they have a live written warning.
Intended activity over the next year
The Home Office undertook a full review of complaints and discipline processes in 2014,
action has been taken as a result of published reports for some new areas of police
regulations as highlighted above. In January, 2016 police misconduct hearings will be
chaired by a legally qualified chair, instead of a senior police officer from the force. Work
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is underway with MOPAC to deliver this and to link this with processes for public hearings.
There are further reviews taking place on the handling of public complaints, including
recording and the role of the Police and Crime Commissioners (MOPAC in London) in this
process.
10. Establishing clear channels of communication with all sections of the community
and other stakeholders on priorities and plans.
Key controls to manage this activity
The Met adopted the National Police Improvement Agency (now College of Policing)
model of engagement in the summer of 2014. This requires the Met to actively seek out
views and opinions on policing, involve all stakeholders and communities in problem
solving, and to have a formal process for feeding back results of that engagement on a
regular basis. The model is being embedded throughout the organisation to ensure that
clear channels of communication on priorities and plans exist on a number of levels across
London.
The Met works with MOPAC to discharge its statutory duty of public consultation across
London. MOPAC are represented at the Met Confidence Board which oversees the Met
Strategic Confidence Plan and directs activity against the target of a 20% increase in
public confidence. There are four key strands to the work programme: engagement,
combating anti-social behaviour, fair treatment and effectiveness in dealing with crime. All
boroughs have their own confidence plan with a review process overseen by the relevant
Area Commander.
Other Met business groups are developing their own confidence plans, supported by the
Community Engagement Team. The Met is in the process of developing a more detailed
performance framework around confidence, allowing activities that we know drive
confidence to be measured and their impact analysed in more detail.
Activity during 2014/15
The bedrock of community policing is at the ward or neighbourhood level. Currently each
ward has a representative panel that meets on a bi-monthly basis to discuss policing
priorities and decide on three ward promises. On many wards this mechanism is
supplemented by ‘virtual’ Ward Panels, which allow a wider range of representation and
involvement of people who might otherwise struggle to meet with the panel on a regular
basis. We have also identified a named police officer for every primary and secondary
school, faith premises and hospital in London, recognising that these institutions form
community hubs that allow the police to engage effectively and efficiently with many and
diverse sections of the community.
At neighbourhood level (each borough contains a small number of neighbourhoods run by
a Neighbourhood Inspector) the Inspector chairs a quarterly neighbourhood panel meeting
where, along with stakeholder and community representation, they identify the most
pressing policing issue to address for the next quarter. At borough level the Safer
Neighbourhood Board, chaired by a member of the community, holds local police and
partners to account on the delivery of policing and other services that will contribute to
safer, more cohesive communities.
In addition boroughs have access to Independent Advisory Groups and independent
Custody Visitor Panels who act as critical friends to represent community view, wishes and
help improve the delivery of policing services. Boroughs are also engaged at senior
stakeholder level in Crime and Disorder Reduction Partnerships. These have a formal role
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in providing services and ensure that high quality engagement, consultation and
communication takes place across the partnership and with all communities.
Intended activity over the next year:
As a global city, many residents and visitors feel a broader community identity, rather than
at a solely geographical neighbourhood level. We are in the process of developing
community profiles to assist us in identifying the diverse existing and emerging community
networks that operate across London. This will help to ensure consistency of service
delivery and high quality channels of communication for all communities. This is supported
through the involvement of Met staff associations who can often provide a very effective
link between the Met and minority communities.
The Met recognises that some groups, young people for example, can be particularly hard
to reach. We continue to develop bespoke programmes such as the Safer Schools
partnership and the Volunteer Police Cadets to ensure that young people from all sections
of the community and with a variety of different needs, are able to engage effectively with
the police, advise on our priorities, help us monitor service delivery and are even able to
engage in service delivery, for example the Volunteer Police Cadets contribute to
ceremonial events and community reassurance initiatives.
Looking to the future, the Met Public Access Board, chaired by AC Territorial Policing, will
monitor the delivery of the Public Access Strategy, intended to ensure that high quality
policing services continue to be delivered to Londoners, in a format that makes the best
use of existing and new technology, supported by a modern and welcoming estate.
11. Developing, communicating and embedding codes of conduct and defining the
standards of behaviour for officers and staff.
Key controls to manage this activity
The Total Professionalism Programme (TPP) is the cultural and behavioural change
programme for the Met, led by AC Professionalism. The TPP is working to ensure that
Met culture is aligned with organisational objectives and priorities, the Met values and
behaviours and the national Code of Ethics for policing. Its overarching aim is to enable
long term performance improvements in order to protect the public and fight crime, helping
make London the safest global city.
The governance arrangements for the TPP have been strengthened during the last year
with the establishment of a refreshed Programme Board. The Programme Board now
includes senior representation from all business groups along with staff and staff support
associations. It has a clear remit to drive professionalism activity across the organisation
and to provide a mechanism that addresses feedback on the effectiveness of the
approaches employed. The programme consists of four outcome focused strands, three
internally focused (standards and behaviour, employee engagement and leadership) and
one public facing (community engagement).
Activity during 2014/15
During 2014/15 the Total Professionalism Programme has had a strong focus on setting
and embedding clear values and standards to guide the behaviour of all staff. It has
achieved this through:
 Launching the Met values and behaviours which incorporate the nationally prescribed
Code of Ethics. Delivery has been through events for leaders who have cascaded the
messages to their teams. There has been a strong focus on engaging staff in
discussions on the ‘ethical dilemmas’ that they may face.
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

Establishing regular engagement events for different tiers of leadership to build
ownership and commitment on the organisation’s vision and its development along with
a structured cascade process for leaders to have local conversations with their teams
on key issues affecting the organisation.
Starting the roll-out of ‘Leading for London’ - a new leadership development framework
that will be piloted on seven units during 2015.
Intended activity over the next year:
The programme team will continue to be responsible for overseeing the work being
undertaken within each of the work strands, aligning activities to ensure consistency with
the overall vision, monitoring progress towards the outcomes set for the programme and
encouraging innovation and good practice at a local level. An audit into the work of the
programme is currently being undertaken by DARA.
The programme has identified a number of priority areas for development during 2015/16
these include: ensuring Met values and behaviours are fully embedded throughout all HR
processes, implementing a new staff survey, reinforcing the standards set by the Code of
Ethics to all staff, reflecting the values and behaviours within Met contract management
and procurement processes and delivering the ‘Leading for London’ pilots.
Directorate of Professional Standards (DPS)
DPS continue to provide regular updates and inputs to training courses and meetings
across the Met which highlight current themes and trends in behaviour or standards that
emerge from DPS investigations. These include recruit training courses, new supervisor
courses, Chief Superintendent courses and a Professional Standards Champions meeting.
In addition to this regular meetings take place with the staff associations, Federation and
Superintendents Association representatives. Additionally, in order to act as a deterrent,
the outcomes of disciplinary hearings are published weekly to ensure that all officers and
staff are aware of breaches of the standards that have resulted in a finding at a hearing.
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E. Governance issues and actions for 2015/16
The Met will face significant challenges throughout 2015/16 and beyond. We will continue
to cut crime and costs and increase confidence against a backdrop of significant change
and evolving demands. Our plans will be informed by six major trends impacting London:
1. Changing Crime - traditional expectations alongside new and changing threats,
demand on the Met is likely to grow faster and further.
2. Austerity - policing on a smaller budget will become the new normal.
3. Economic growth - growth will shape social and economic change in London – at a
pace that will be different to the rest of the country.
4. Advancing Technology - communication is going pure digital, pure mobile.
5. Population Growth - London will remain one of the world’s most ethnically-diverse cities
and will grow further, accentuating differences between London and the rest of the UK.
6. Political Change - In 2016 we will have a new Police & Crime Plan and a new Mayor.
We remain committed to implementing a governance framework that supports the delivery
of our strategic objectives including setting out clear accountabilities and robust processes
and will continue to build on improvements made during 2014/15.
As a result of our 2014/15 annual review and consideration of the DARA audit opinion we
have identified seven areas which will be addressed over the next twelve months to further
improve the Met’s approach to governance and our internal control environment.
Strategic Governance Framework
We intend in 2015/16 to continue to develop our strategic governance framework to create
a robust cycle from strategy setting, through planning, financial tracking and reporting, risk
management, performance and assurance processes to ensure delivery.
Action:
During 2015/16 we will operate a strategic business planning cycle which will define and
drive much of the core activity and decision making across the Met, including our strategic
assessment and One Met Strategy, Strategic Business Plan, our Medium Term Financial
Strategy and budget process, and our performance, risk and assurance processes. This
will include:

Refreshing the One Met Strategy by June 2015.

Continuing to embed and enhance the Met’s decision making forums in accordance
with recommendations from recent audits.

Developing the Met’s the Strategic Business Plan against a number of key driver areas
which pick out activity critical to the delivery of Met objectives and implementing robust
scrutiny of these.

Developing our strategic approach to partnership management.

Running a priority based budgeting process.

Rolling out the One Met Scorecard with the aim of improving performance
conversations throughout the Met.
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
Continuing work to improve risk management maturity to a level where it delivers
consistent working outcomes testing this by conducting maturity assessments in
quarter 3 of his year.

Continuing work to strengthen audit, inspection and review services in the Met in
accordance with the three lines of defence model. We intend to produce a
comprehensive Met assurance plan that maps to key risks by February 2016.
Change Governance
The Met is developing a new operating model, the One Met Model 2020 (OMM 2020), for
implementation by 2019/20. This will set out our vision for policing in London and how we
intend to achieve that, describing the structures, systems, processes and capabilities
needed to meet our strategic objectives. A robust framework for change governance will
continue to be implemented throughout 2015/16 to enable delivery.
Action:
During 2015/16 we will:
 Set clear design principles.

The development of the OMM 2020 will use Prince 2 and Managing Successful
Programmes (MSP) methodologies and the Treasury ‘Green Book’ Business Case
model.

Deliver the strategic outline case for the OMM 2020 which details our approach for
delivery detailing how this will be managed through change programmes, setting
parameters to shape cost savings and service delivery options, and proposing a
governance structure.

A further outline business case will be delivered in Autumn 2015/16 which will assess
the options, determine value for money, ascertain affordability and funding
requirements and plans for successful delivery.

The current Met Total Technology Programme (TTP) for Digital Policing will be
reviewed under the DP TOM and integrated with the overall OMM 2020.

The DP TOM will be achieved through: a new model of engagement that ensures
functional design and delivery of cost effective systems; the outsourcing of all solution
development and service delivery; and the consolidation of DP to manage relationships.

The OMM 2020 work will be led and managed through new Met governance
arrangements set out in Section D. The Portfolio Design Delivery Board will ensure
that all proposed change is in line with the overall OMM 2020 and will manage delivery
of change programmes.

Governance of the DP TOM will continue to be integrated with the overall change
programme.

Portfolio Delivery Boards will oversee programmes and projects within their scope.
They will prioritise investment decisions and ensure that change activity is sequenced
and risks, benefits and dependencies are managed. They will drive business cases.
Progress in all portfolios will be integrated through a Strategic Design Authority.

Business case teams will work in their portfolio under an Operational Lead and then
portfolio Programme Manager. A Design Authority Assurance Working Group will
ensure overall integrity of the OMM 2020 design and manage complex
interdependencies. Each Programme will develop an integrated assurance and
approvals plan.
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The Met will continue to review these new governance arrangements for the programme
during 2015/16, ensuring that they are robust. This reflects the conscious decisions that
the Met has made to operate a very challenging change programme with inherent high
levels of risk to delivery.
Financial Control and Value for Money
The Met’s Financial Governance Framework comprises structures, financial systems,
policies, people and controls that aim to safeguard public monies and assets against
impropriety and fraud, achieve Value for Money (VfM) and deliver a balanced budget. The
Met supports devolved local accountability with effective internal control. Whilst Internal
Audit has found financial systems to be effective in terms of financial governance, the
financial control framework is monitored and reviewed throughout the year to improve
accountability and compliance.
Action:
The Met will continue to adjust financial monitoring and control methods to align with fast
moving programme and project driven expenditure models, particularly in capital planning
and expenditure against Treasury Green Book principles. We will embed Finance
Business Partnering to support service leads across the Met in delivering VfM.
Ultimately Management Board members must ensure that internal controls in their areas
operate adequately and that all relevant staff comply. Members are required to sign a
Statement of Internal Control for their areas - in 2015/16 we will enhance this control. In
broad terms improvements to financial controls fall under three key headings:
Governance arrangements and approvals: MOPAC/Met governance arrangements are
key to financial governance, to ensure that financial decisions are properly informed and
that risks, impacts and costs/benefits are considered. During 2015/16 we will focus on:







The One Met Model 2020 to identify achievement of savings and risks to delivery
both within our back office functions and our front-line services (i.e. improved
productivity)
Medium term financial planning (to the end of the decade) to meet Met objectives,
and to ensure that the organisation can deliver within the projected financial
envelope.
Embedding budget setting as part of business planning.
Improved local reporting and controls including KPIs.
Improved business cases to ensure that Board decisions are fully informed.
A whole system approach ensuring that VfM is embedded across the Met.
Enhanced risk management processes to identify, prevent and mitigate risk
Maintaining accurate and complete accounting and effective stewardship:
Management Board Members must maintain expenditure within budget, maintain effective
financial controls, uphold the accuracy and integrity of financial information and systems
and achieve VfM. During 2015/16 we will focus on:

maintaining expenditure within budget and effective financial control.

ensuring tight budgetary control through local forecasting and variance analysis within
Monthly Monitoring Reporting (MMR).
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
ensuring effective stewardship at a local level such that managers and staff are
compliant with the relevant regulations, policies and procedural guidance.

operating financial system and financial data security measures.
We will embed current initiatives including encouraging the even and regular distribution of
financial housekeeping activities across the entire year to improve monitoring and our
ability to identify potential irregularities; faster goods receipting: in year balance sheet
reporting to improve the quality of financial reporting and faster closure initiatives to
improve management information for policy and planning.
The Met will, through the commercial plan, improve VfM through market provision of back
office and then middle office functions. There is a powerful link between commissioning
and our future target operating model. The Met’s financial strategy will aim to:

Maximise our future frontline spend by aiming to keep expenditure on back office
functions to about 15% by 2019/20, driven through our commercial strategy.

Transform our services both internally and with partners and the public.
We plan to close the 2016/17 gross budget gap of £260m, part of our £800m total gross
savings requirement between 2016/17 to 2019/20, through the One Met Model 2020. High
level financial targets in the Strategic Outline Business Case will inform savings options for
Outline Business Cases (OBCs) using the same challenge methodology as priority based
budgeting. The OBC, shaping work over the next four years, will focus on agreeing
2016/17 savings to ensure submission of a balanced budget to the Mayor by October 2015.
Financial Assurance in the MPS: Management Board Members must provide assurance
that internal controls are working adequately. This is achieved through ‘three lines of
defence’ - local reviews, corporate reviews and ultimately internal and external reviews
and audits. We will develop activity in all areas during 2015/15 and focus on:

three active DARA audits where internal controls are rated as ‘limited’. These include
the Met Contract Management Framework, Management and Control of Local
Inventories and Budgetary Control Framework.

three outstanding ‘high risk’ recommendations.
These include the Contract
Management Framework; CT revenue funding and warehouse stock.
Commercial and Contract Management
The adoption of a commercial approach will be a key lever in achieving savings to 2020.
We continue to make progress as a result of the Commercial Plan, termed the 007
Programme. The majority of current outsourced contracts are due to be re-competed by
the end of 2015/16. The aim is to reduce the number of contracts and work with a small
number of strategic suppliers, with projected savings of £206m in 2015/16. This requires
the Met to have a robust commercial and contract management approach.
Action
During 2015/16 we will:
 Develop and embed a commercial culture across the Met supported by a new
Commercial Centre of Excellence.

Deliver new contract awards including Fleet Managed Service, National Uniform
Managed Service and System Integration Application Management (SIAM), Hosting
and later Networks.
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
Continue market testing and outsourcing of key back office services, including a key
contract for transactional HR and Finance/Procurement.

Establish the next phase of the Commercial Plan with greater focus applied to ‘middle
office’ activities.

Develop our intelligent client function to ensure that key contracts with suppliers are
managed to the highest professional standards and value for money is achieved.

Embed our contract management framework and training programme.

Establish governance arrangements to ensure the effective delivery of all aspects of
the commercial strategy in support of overall MetChange.
This includes ensuring that the Met has the commercially capable, experienced resources
necessary to effectively deliver the commercial strategy, and establishing organisational
arrangements for their most efficient use. The Met will develop a “Commercial Centre of
Excellence” to deliver a programme of review and transformation across the organisation.
Confidence in Policing
Public confidence is crucial to delivering a good service for the people of London. It is at
the heart of the principles of legitimacy and policing by consent, fundamental to British
Policing. Evidence suggests that people who feel confident are more likely to report crime
and work with us to achieve our objectives. A focus on public confidence allows us to
tackle key issues and tailor community engagement. The Met recognises the significant
moral, operational and statutory imperative to engage with all of our communities.
Public confidence in policing London is stable with about two thirds of Londoners saying
they are confident in local and London wide policing. However this varies significantly
across London boroughs. To achieve the MOPAC target of a 20% improvement in public
confidence by April 2016 we need sustained and continuous improvement.
Action:
The Met Confidence Plan 2015/16 sets out success criteria including an evidence based
approach to understand and engage with communities that we serve and use this to shape
service delivery; empowered officers and staff, anticipating how a changing London will
affect demands on policing and our capacity to respond; improving every interaction with
people; and keeping Londoners informed. Met Confidence Board, led by the AC Territorial
policing has a clear remit to drive confidence and satisfaction in policing London.
During 2015/16 we will:
 Improve our understanding of young Londoners through the Met/MOPAC youth survey
and youth engagement.

Increase our understanding of minority communities and of the role of religious
organisations in the community, including through Faith Action Audits.

Improve our understanding of hate crime and our response to communities including
disability hate crime.

Develop our use of media, such as BBC documentary screenings and social media, to
drive engagement and awareness.

Increase direct engagement though community events, open days, the Ride Along
scheme, our Citizens Academy, and increase Police Volunteer Cadets to 5,000.
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
Develop evidence from our Listening to London campaign, the Rate my PC pilot and
other feedback to inform our engagement with communities.

Improve operational training and internal governance to drive improvements in
Confidence and Satisfaction.
Information Management
Information Management is a crucial enabler of the Met Operating model and of delivering
policing outcomes for London. Met Information Management processes are subject to
increasing review and remain high risk.
Action:
 An Information Management Strategy is being prepared to set out the Met’s objectives
for information management. This will be finalised by June 2015.

The Information Security and Assurance Board will continue to receive regular
progress reports on actions to improve information management and information
security risks.

Our recovery action plan to improve corporate performance with Data Protection
Subject Access and Freedom of Information requests, resulting in significant
improvement to date, will continue in 2015/16. Our new delivery model to centralise
our processes for sustainably dealing with Freedom of Information requests and with
Data Protection subject access requests will be implemented during 2015/16.

A Records Management toolkit and working practices, amended during 2014/15, will be
rolled out across the Met as part of the records management implementation plan
during 2015/16 and 2016/17. We intend to conduct Information Management Maturity
Assessments at completed sites to measure maturity levels in local practices. This will
identify further areas of improvement for Information Security and Assurance Board.

During 2015/16 we will also review the Met Records Retention Schedule in light of a
recent Supreme Court judgement; implement the Government Security Classification
Scheme within the Met once national police guidance is finalised; and conduct
information assurance audits in line with the agreed audit plans of Information Security
and Assurance Board.
Ethics and Integrity
The current change programme is the most significant since the Met was founded in 1829.
Understanding culture and how this drives observable behaviours is critical to embedding
change effectively. The Met recognises the importance of an ethical values-driven culture
with a focus on integrity, courage, compassion and professionalism, fostering professional
accountability and personal responsibility to champion positive behavioural change.
Action:
The Total Professionalism Programme (TPP) is the Met’s cultural and behavioural change
programme. The TPP aims to ensure that Met culture is aligned with strategic objectives
and priorities, Met values and behaviours and the national Code of Ethics for policing. The
Programme aims to enable long term performance improvements and embed values of
integrity courage, compassion, and professionalism and associated behaviours.
The programme has identified a number of priority areas for development. During 2015/16
we will:
 Ensure that Met values and behaviours are fully embedded throughout HR processes.
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
Implement a new staff survey.

Reinforce the standards set by the Code of Ethics to all staff, reflecting the values and
behaviours within Met contract management and procurement processes.

Deliver the ‘Leading for London’ pilots.

Introduce a new model standardising Local Professional Standards Units.

Implement new regulations and disciplinary processes from January 2016.
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F Declaration
We propose over the coming year to take steps to address the above matters to further
enhance our governance arrangements. We are satisfied that these steps will ensure that
Met governance processes will remain effective in a changing environment. We will
continue to monitor their implementation and operation, including through Met risk
management processes.
Signed
Signed
Sir Bernard Hogan-Howe
Craig Mackey
Commissioner of Police of the Metropolis
Deputy Commissioner of Police of the Metropolis
Date 31 May 2015
Date 31 May 2015
Protective Marking
Suitable for
Publication Scheme
Title and Version
Purpose
Relevant to
Creating branch
Authors
Date created
Date to be audited
Date to be re-signed
None
Yes - when signed
CPM Annual Governance Statement 2014/15 (Unaudited)
As part of the Corporate Governance Framework, an Annual
Governance Statement is completed, signed by the
Commissioner and Deputy Commissioner and published with the
Met Statement of Accounts
Met Management Board and MOPAC
Professionalism, MetHQ
Paul Clarke and Jo Collins, MetHQ
May 2015
September 2015
September 2015 (following audit)
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G Glossary of terms
ACRONYM
AC
ACAS
ACPO
AGS
BSMI
CAIU
CFO
CIPFA
CPM
CSC
CST
DAC
DARA
DLS
DP
DP TOM
DPA
DPS
EHRC
EIA
EMS
FBP
FoIA
HMIC
ICT
IFAC
IPCC
ISAB
MET
METSEC
MMR
MOPAC
MPS
NPCC
NUMS
OBC
OCU
OMM 2020
POCET
PSSC
SIAM
SMIU
SMS
SOLACE
SOP
STM
STRIDE
DEFINITION
Assistance Commissioner
Association of Chief Police Officers
Annual Governance Statement
Borough Support Management Information
Civil Actions Investigation Unit
Chief Financial Officer
Chartered Institute of Public Finance and Accountancy
Commissioner of Police of the Metropolis
Civil Service Compensation Scheme
Complaint Support Team
Deputy Assistant Commissioner
Directorate of Audit Risk & Assurance
Directorate of Legal Services
Digital Policing
Digital Policing Target Operating Model
Data Protection Act
Directorate of Professional Standards
Equality and Human Rights Commission
Equality Impact Assessment
Environmental Management System
Finance Business Partners
Freedom of Information Act
Her Majesty’s Inspectorate of Constabularies
Information and Communication Technologies
International Federation of Accountants
Independent Police Complaints Commission
Information Security and Assurance Board
Metropolitan Police Service
MPS Security
Monthly Monitoring Reporting
Mayor’s Office for Policing and Crime
Metropolitan Police Service
National Police Chiefs’ Council
National Uniform Managed Service
Outline Business Case
Operational Command Unit
One Met Model 2020
Public Order and Civil Enquiry Team
Professional Standards Strategic Committee
System Integration Application Management
Serious Misconduct Investigation Unit
Safety Management System
Society of Local Authority Chief Executives
Standard Operating Procedures
Strategic Training Meeting
Strategic Inclusion, Diversity and Equality Strategy
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TNO
TPP
TTM
TTP
VfM
Total Notifiable Offences
Total Professionalism Programme
Tactical Tasking Meeting
Total Technology Programme
Value for Money
175
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